The Use of Regulatory Data to Improve Supply-chain Traceability and Combat IUU Fishing

In the over 30 years I been in commercial fishing, research and management, there have been a lot of changes, but generally, a very stable type of people has been the norm, so I'm excited and intrigued when I see new "people" coming in.

A while ago Jeff Douglas, an interesting entrepreneur from the IT industry, that has worked on various fisheries and marine projects contacted me (along other people) with his 'plan". He was getting into traceability with the focus on the mechanics of implementing and integrating IT systems to enable the secure capture, exchange, and processing of digital seafood traceability data. He produced an interesting and lucid proposal I’m quoting below:

His objective is to provide a “digital passport”—ideally, with a cryptographically provable chain-of-custody—that follows seafood as it moves through the supply chain: from harvest, through processing, export, import, and wholesale, to retail sale.

This supply-chain is a complex one, mixing both public and private sector organizations, at all stages of harvest and handling:

All images are from Jeff Douglas report

What Data Exists?

Traceability can mean many things to different audiences. For our purposes they define it in terms of Key Data Elements (KDEs), and the organizations that collect these. Existing public and private sector databases often record:

It is fair to say that much of the relevant data is already captured in electronic systems (databases)—either by regulators or by private sector organizations. However most exchanges of this data occur in paper form: through printing, scanning, and faxing or emailing of documents. This is inefficient, and creates an elevated risk of documentation fraud or mislabeling.

For both commercial and political reasons, it seems unlikely that a single “grand database” of global seafood traceability data could be assembled. Of necessity, the government (regulatory) and private (commercial and NGO) sector organizations will continue to maintain independent databases. Additionally, there are unique challenges involved in designing interoperable IT solutions: particularly, given the multi-jurisdictional nature of the seafood supply-chain, and the number of participants; i.e. multiple regulators, customs agencies, food safety agencies, the seafood industry, and independent certification providers.

The data is difficult to harmonize. For valid scientific, commercial and political reasons regulators require different KDEs. Introduction of a “global” catch report is, therefore, problematic. However, a standardized extract of catch details—from existing databases—is feasible.

Enabling this process is their objective.

Why do we Need Standards?

The structure of the seafood supply-chain implies the need to develop standards—and agree these jointly between regulators and industry. This becomes essential when electronic traceability scales to, eventually, include all harvest.

They can find technical standards in-use within the cold-chain segment—for packaged goods—but these are largely unknown to fisheries regulators, and have a high degree of complexity to implement. Conversely, many aspects of importance to fisheries regulators do not have accepted mappings—and certainly there are no global standards—when one seeks to integrate this data within supply-chain systems.

For example, there are no globally interchangeable electronic records covering: registration of vessels; recording of crew details/transfers; issuance of licenses, permits and quota; or, recording and reporting of catch/harvest location. Additionally, there are significant differences in how fisheries are managed (the mix of capacity, input and output controls).

This reflects in the differing Key Data Elements (KDEs) required by each fisheries regulator.

A Standards Body Will Fix This?

Yes, and no.

There are standards bodies who can address the technical elements within one domain, but none that act across the entire group of broader stakeholders. For example, national fisheries regulators often set their own technical/data standards (and in some cases, RFMOs or transnational bodies, such as the EU, do likewise). Within the supply-chain, the GS1 organization is influential, but does not provide implementations of their standards in a form easily taken up by fisheries regulators.

Additionally, there is valuable work occurring at many levels on traceability and interoperability, including:

Initiatives by the United Nations Food & Agriculture Organization; whereby RFMOs and National Fisheries Regulators exchange vessel particulars on a voluntary basis, to assist in building a history of fishing vessels identifiers.

The Global Food Traceability Center (GFTC) and GS1.org are working to define Key Data Elements (KDEs) from the perspective of mainstream cold-chain IT systems, in a manner that facilitates integration and interoperability.

Private sector traceability providers have demonstrated the ability to collect data, and to provide it to regulators, wholesalers and retailers—including limited interoperability between competing IT vendors.

A number of regulators, most notably within the United States and European Union, have published data standards for electronic catch reporting. However, some standards do not address aquaculture/processors and/or are restricted to exchanges via trusted government data networks only—hence, they are not directly suitable for supply-chain use.

All these initiatives are encouraging, but what appears to be lacking is an initiative focusing exclusively on the most pressing gap in interoperability. This occurs at the intersection of the regulatory sphere—fisheries, food safety and customs regulators—when their IT systems must interface with the systems operated by harvesters, processors and the cold-chain.

Defining Success

Our Key Performance Indicator (KPI) can be stated as follows: “What percentage of the global seafood harvest is reported via a regulator participating in the Traceability Interoperability Initiative?”

They have a particular focus on the Top 20 national regulators and Top 10 RFMOs.

Put simply, seafood regulators should be able to implement—at reasonable cost—software modules within their existing IT systems to provide the seafood industry with electronic equivalents for paper documents of record (i.e. fishing permits, receipts for catch matched against quota). Such electronic representations must be digitally signed, tamper-proof, and verifiable. It is of equal importance that these documents are standardized in presentation (i.e. XML schemas): so that industry, certification bodies, traceability providers, NGOs and other private sector organizations may integrate this data efficiently.

Only once this occurs, do they have a feasible path towards true electronic seafood traceability (Additionally, in approaching this discussion, they must be mindful that, despite the end objective being a fully electronic system, there is a requirement for the foreseeable future to support hybrid paper-based, and partially-electronic options also)

Traceability must begin with the regulators: Certain functions (e.g. authorizing vessels to fish, issuing quota, and approving exports) are inherently governmental functions. As such, these functions cannot be “outsourced” to the private sector: yet, this data is critical for the chain-of-custody and must also flow to private sector participants; i.e. harvesters, processors, and customs agents.

By analogy, this role is similar to that of a Land Registry (recording deeds), a Department of Motor Vehicles (issuing drivers licenses), or a Passport Office (issuing passports). In each case private sector organizations and foreign governments rely on the data—and there are well-defined methods to obtain this information electronically (i.e. an insurance company querying a driving record; biometrics embedded on an RFID chip within a passport). The challenge within seafood traceability is to find a similar path towards public-private sector data interoperability.

Of course, our KPI is easy to state, but rather more difficult to implement in practice. They turn to this next.

How do we get there?

They propose to establish:

An open, non-profit, technical organization with membership extended to seafood regulators, the seafood industry, and all technology suppliers having an interest in seafood traceability.

To hire a core set of technical experts who will become the preeminent source of deep knowledge on the relevant supply-chain data standards and relevant fisheries data standards. They do not envisage this to be a static process, but one that evolves over time as new standards are developed and implemented by our members.

To maintain a publically accessible GITHUB repository, which codifies this knowledge through a series of open source reference implementations—widely adopted by fisheries regulators in conjunction with their existing IT providers. (To include security roles, and scaffolding to enable regulators to efficiently wire implementations to existing databases.)

To maintain a website of participating fisheries authorities: including public keys to facilitate verification of digitally signed traceability documents. (This website will contain only public keys, and redirect links to the relevant implementation by each fisheries regulator. No traceability data is received or stored.)

Perhaps, more importantly, what they are not:

They are not a primary standards organization. They seek to implement existing standards, and to identify real-world issues as they arise (i.e. different methods of coding fish species), and provide the appropriate data mapping tools.

They are not a portal or repository of traceability data. They provide only code (software). Regulators handle all digitally signed documents directly. For example; basic vessel details (Good Standing Lists) might be public (where they are now), commercially sensitive data—such as receipts for catch records—are provided by the fisheries regulator direct to the harvester (via web or email)— mirroring existing paper-based workflows. They are not involved in these processes.

They do not seek to become an IT supplier to fisheries authorities. Instead, they propose that existing IT professionals (whether in-house or contractors) become members, and then perform the integration work directly with their clients.

They are not an electronic logbook supplier; catch reporting vendor; or traceability provider. However, organizations of this nature are welcome as members (and they anticipate many will wish to join).

Current Status:

They are seeking funding! Once they have this, they will start work immediately—in collaboration with a core set of “early-adapting” fisheries regulators and private sector traceability suppliers (who have agreed to contribute to the development, and assist in beta testing, of the data exchange APIs). Our intention, over time, is to move to a self-funded model: perhaps, based on the volume of seafood processed by each regulator. However, to “bootstrap” this initiative, and prove it’s worth to regulators, they anticipate the majority of early funding will need to come from private sector and philanthropic sources.

Structure & Governance

They propose that all participants in the seafood supply-chain have a seat at the table. Only in this manner can they accommodate the unique considerations of each stakeholder: data sovereignty, in the case of regulators; commercial sensitivities and privacy, in the case of industry; technology choices, in the case of IT professionals.

Different countries (and even individual fisheries) have differing views on acceptable fishing practices. To properly support all participants, it is essential that they not be viewed as a lobbying organization. They can take no position on specific fisheries policies; catch methods; or any other aspect of fisheries management.

Their role is narrow: To facilitate efficiency and transparency within the supply chain. Primarily, through offering electronic/automated means to exchange data that is handled manually, in paper form, at the present time.

Noting the nature of the work, they believe the board should consist primarily of technical/subject-matter experts. They are seeking a balance between regulators (preferably, through their IT suppliers—either in-house or contractors), the fishing industry (to ensure they properly address concerns regarding data confidentiality and commercial sensitivity of information), and the technology industry (to ensure they adopt best practices for all engineering work). Individuals interested in serving in some capacity on the board, or otherwise being involved with this initiative, are invited to provide an indication at this time.

This is a small, tightly focused initiative. To avoid the outlays of a standalone governance structure, they are in discussions with a non-profit incubator. (And will update, pending approval.) The option of joining an existing organization was also considered. However, due to the requirement for strict neutrality on fisheries management practices, and furthermore, a desire to avoid any perception of favoring one participant over another (i.e. regulators or industry), it was felt that a standalone initiative was more appropriate. This said, over time, they might revise this view if another home becomes suitable.

On location, they propose Massachusetts, USA—based on the nexus of technology and seafood expertise. They have received a few comments suggesting alternate locations (all of which, themselves, would give rise to similar questions!) Although they have to pick one location initially, they are open to collaborations with other academic and non-profit institutions, particularly those willing to house developers, interns or researchers performing complementary work under this initiative (our intention in designating this an open-source project is to encourage a broad range of contributors, beyond the core team).

Benefits

The benefits to regulators and the seafood industry are substantial:

For regulators: Our approach can reduce or eliminate the cost of negotiating proprietary data-exchange solutions for each traceability provider, or alternatively, the difficulty in developing and supporting a country (or fishery) specific API. At point of import, interoperability allows the digital chain-of-custody to extend back to the original national regulator (or RFMO).

For industry: Interoperability avoids the cost of integrating and testing with each regulator—using disparate technical standards—and promotes traceability across multi-jurisdictional supply-chains. In particular, lacking interoperability, it becomes difficult to maintain a strong-chain-of-custody, as data conversions are not permitted on digitally signed data.

For IT Professionals: Access to a well-tested, professionally developed and documented code base is always attractive when developing solutions—whether this is used to integrate with an existing Fisheries Information System, Vessel Monitoring System or Catch Reporting System, or to automate exchanges with such systems on behalf of commercial clients within the seafood industry. The need for interoperability is obvious: With at least 40 significant fisheries regulators, and likely a similar quantum of traceability providers, if one approaches this on a point-to-point integration basis, the number of system combinations to be integrated and tested would be staggering (and simply not feasible); i.e. 40 x 40 = 1,600.

Seafood traceability is only as strong as its weakest link: The ability to electronically obtain vessel particulars, fishing licenses/permits/quota, and vessel location/track data (where applicable) becomes key to the entire chain-of-custody. Such data sources are essential to developing an evidentiary-grade seafood traceability solution.

Of specific interest are the Key Data Elements (KDEs) which establish: vessel/facility particulars (“who”); the entitlement to harvest (“what”); and the location of harvest (“where”/“when”).

They are mindful that simplicity is key: Technical solutions that minimize the change needed to systems in-use by fisheries regulators and industry are far more likely to be widely adopted, making interoperable seafood traceability a reality.

Managing the security surrounding this data, so that different participants can receive different levels of access, is one of the key discussions that this initiative is well placed to undertake, with all stakeholders represented.

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The views expressed here are my personal ones, they don't reflect the position of any of my contractors.

Finally, apologies in advance for my terrible grammar and orthography!I'm dyslexic and never had any formal education in English, I just learned the language along the way while working in fishing boats.